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#899254 - 02/04/08 07:33 PM second chance checking quick question
In the middle of it Offline
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In the middle of it
Joined: Oct 2000
Posts: 276
Central US
We're implementing a second chance checking product. I've read through a few posts here and found references to CRA recognition for the product. Elsewhere I've read that there would be no special CRA implications since the program is not geared to LMI consumers - but rather to those that had a problem managing an account in the past. Any suggestions for getting the most benefit from this product from a CRA perspective?

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#899286 - 02/04/08 07:52 PM Re: second chance checking quick question In the middle of it
Pale Rider Offline
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under the Lone Star
All I could suggest to document that a majority of the users were LMI is that you have them complete a short survey with a check next to a series of income groupings. If they complete the survey, you can then compare the group to the medium income for your AA and have evidence to show the examiners that a majority of the second chance users are LMI.
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#899309 - 02/04/08 08:00 PM Re: second chance checking quick question Pale Rider
Mrs. Rizzo Offline
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Curled up by the fire...
Perhaps if you have them go through some sort of financial literacy program or class first you might get credit for that???
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#899503 - 02/04/08 09:19 PM Re: second chance checking quick question Mrs. Rizzo
In the middle of it Offline
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In the middle of it
Joined: Oct 2000
Posts: 276
Central US
Good thought. However any counseling feature is not planned. This is going to be an immediate alternative offering if the applicant won't be accepted for a standard checking account. It looks like we'll possibly be able to have the demographics evaluated after we have enough accounts to work with. I wanted to make sure I wasn't being too negative in my thinking and missing a point I had to make. Apparently someone was told up front that there would be CRA benefit to be had...but I wasn't seeing such a clear cut case. If we can show we're able to offer banking services to consumers that had to do without previously, well, it does sound good. But the second chance customer isn't the exact concept of "unbanked" that I had in my CRA mind.

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#899688 - 02/05/08 01:06 AM Re: second chance checking quick question In the middle of it
Don_Narup Offline

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Joined: Jul 2001
Posts: 3,708
Las Vegas Nevada
(It looks like we'll possibly be able to have the demographics evaluated after we have enough accounts to work with)

Be careful. Just because a persons residence may be in a LMI Census Tract doesn't mean the individual themselves are LMI people.

Opinion
"Unbanked" was a nice word HUD and others in charge of regulatory agencies used to do away with saying "illegal alien" It was said ofrten in their speaches indicating how Sub-Prime lending was allowing the "unbanked" to acheive the american dream of home ownership,

Don't think they use this anymore
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